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Mark is always glad to hear from visitors, readers, and other interested parties so feel free to contact him. You can do so by completing this form, emailing Mark at councile@aol.com, or calling his office at 703-509-3734.

The first myth about compliance program assessment is that it is an optional part of an effective compliance program. The same sentence in the Sentencing Guidelines that mandates a hotline also mandates compliance program assessment. And, even if program assessment were not mandatory, it is would be incumbent on your organization to undertake assessment. Org […]

We are contacted by headhunters because we know a lot of compliance officers and we know whether they are available. However, it is extremely difficult to help these folks as they often have no idea what a compliance officer does. They are generally working from a job description written by someone in HR who also has little idea what a compliance officer doe […]

While there will continue to be new posts on longer topics on ethicswhisperer.com, I also encourage you to follow markpastin.com, which is updated more frequently and focuses on issues of the day. Of course, your comments are always welcome on any of our sites.

Hear yea! Hear yea! Hear yea! The next hot word in compliance will be UPQUALING. This, of course, is on the model of UPCODING. Healthcare reform is a gamble on the idea that incentives can be given to lower the cost of care while maintaining or improving its quality. This has been tried before with limited success under the rubrics "managed care," […]

Secretary of the US Department of Health and Human Services Kathleen Sibelius recently announced that health plans offered through exchanges will not be considered Federal health plans – and many breathed a huge sigh of relief. Not so easy.What the Secretary's announcement means is that plans purchased through exchanges will not be administratively unde […]